NORTH CAROLINA DIVISION OF AIR QUALITY
                                       
                               Air Permit Review

Region:	Winston-Salem
County:	Rockingham
NC Facility ID:	7900090
Inspector's Name:	Hilary King
Date of Last Inspection:	04/23/2014
Compliance Code:	3 / Compliance - inspection
Facility Data
Applicant (Facility's Name):	MillerCoors LLC - Eden Brewery
Facility Address:	863 East Meadow Road
	Eden, NC  27288

SIC:	2082 / Malt Beverages
NAICS:	31212 / Breweries
Facility Classification:	Before:	Title V (TV)	After:	Synthetic Minor (SM)
Fee Classification:	Before:	TV	After:	SM
Permit Applicability
SIP:	Yes
NSPS:	Yes (40 CFR 60, Subpart IIII)
NESHAP:	Yes (40 CFR 63, Subparts 4Z & 6C)
PSD:	No
PSD Avoidance:	No
NC Toxics:	No
112(r):	Yes (Level 3)
Other:	N/A
Contact Data
Application Data
Application Number:	7900090.14B
Date Received:	11/04/2014
Application Type:	Modification
Application Schedule:	State
Existing Permit Data
Existing Permit Number:	03116T22
Existing Permit Issue Date:	04/08/2013
Existing Permit Expiration Date:	11/30/2015
Facility Contact
Michael Lozano
Utilities Manager
(336) 627-2100
863 East Meadow Road
Eden, NC  27288
Authorized Contact
James Smith
Vice President and Plant Manager
(336) 627-2204
863 East Meadow Road
Eden, NC  27288
Technical Contact
Michael Lozano
Utilities Manager
(336) 627-2100
863 East Meadow Road
Eden, NC  27288

 Review Engineer:  Christopher W. Lewter, P.E.
 Review Engineer's Signature:
 Date:
                          Comments / Recommendations:
Issue:	03116R23
Permit Issue Date:	03/10/2015
Permit Expiration Date:	11/30/2015

 INTENTION OF APPLICATION
An application requesting modification of permit 03116T22 was received from MillerCoors LLC on November 4, 2014.  The application contained the appropriate signature, number of copies, and fee, so the application was considered complete for processing at that time.  A complete chronology can be found in the following section of this review.  Any necessary facility and contact information was updated in the DAQ IBEAM database.  It was confirmed that the company remains registered, in good standing, with the NC Department of the Secretary of State as of the date of this review.  The application requests that several boilers, ash handling system (ES-4), and wastewater treatment plant (ES-36) and any associated control devices, and several exempt sources, be removed from the permit and the facility be reclassified as SM.

 CHRONOLOGY
The following table illustrates the sequence of events for this revision.

                                     Date
                                     Event
                                   Due Date
                                 Date Received
                                    Comment
                                  11/04/2014
Application received 
                                      ---
                                      ---
Application complete for processing; clock started
                                  11/06/2014
Acknowledgement letter sent
                                       
                                       

                                  12/05/2014
Additional information request sent to Michael Lozano, Utilities Manager, via email
                                  12/19/2014
                                  02/19/2015
                                  (complete)
See attachment A; clock stopped; due date ultimately disregarded due to facility needing more time to gather information
                                  12/17/2014
Additional information received from Taylor Loftis, P.E., Senior Consultant with Trinity Consultants (facility's consultant), via email
                                      ---
                                      ---

                                  12/18/2014
Additional information request sent to Mr. Loftis via email
                                       
                                       

                                  12/30/2014
Additional information received from Mr. Loftis via email
                                       
                                       

                                  12/31/2014
Additional information request sent to Mr. Loftis via email
                                       
                                       

                                       
Additional information received from Mr. Loftis via email
                                       
                                       

                                  01/05/2015
Additional information request sent to Mr. Loftis via email
                                      ---
                                      ---
See attachment A; clock stopped
                                  02/19/2015
Additional information received from Mr. Loftis via email
                                       
                                       
See attachment A; clock restarted
                                  03/06/2015

                                       
                                       
See attachment A
                                  03/10/2015
Permit issued
                                       
                                       
None
DESCRIPTION OF BUSINESS
According to the report for the latest compliance inspection performed at the facility by Hilary King, DAQ-WSRO Engineer, and dated April 24, 2014, the facility is "...a beer brewing and packaging facility....The facility operates 24 hours per day, five days per week, and 50 weeks per year, for a total of 6,000 hours per year...."  As previously mentioned, the application requests that several boilers (ES-1  -  ES-3, and ES-6), ash handling system (ES-4), and wastewater treatment plant (ES-36) and any associated control devices, and several exempt sources (IES10, IES11, IES17, and IES25), be removed from the permit and the facility be reclassified as SM.

Mr. King noted the following permitting issues:

  "Bagfilter CD-11C, listed as a control device for the raw materials unloading and transfer system (Insignificant Emission Source ID No. IES18) is no longer installed and should be removed from the Insignificant Source list."  The bagfilter was removed as suggested by Mr. King.  It is noted that this permit writer asked Mr. Loftis numerous times if this was acceptable, or not, but no response was received (see attachment A).
 "Bagfilter CD-12C, listed as a control device for the grain transfer system (Insignificant Emission Source ID No. IES19) is no longer installed and should be removed from the Insignificant Source list."  The bagfilter was removed as suggested by Mr. King.  It is noted that this permit writer asked Mr. Loftis numerous times if this was acceptable, or not, but no response was received (see attachment A).
 "The facility's coal pile (Insignificant Emission Source ID No. IES25) is currently called a "cold" pile on the Insignificant Emission Source list.  A correction in the spelling is necessary."  No revision was necessary since this source was removed from the Insignificant / Exempt Activities attachment to the permit.

During the course of this review, it was discovered that the permitted emergency generator (ES-37) and fire pumps (ES-38 and ES-39) qualify for exemption from permitting per 15A North Carolina Administrative Code (NCAC) 2Q .0102(c)(2)(B)(v)(III)  -  emergency use generators...that have a rated capacity of no more than...590 kW (electric) or 900 hp for diesel-fired...engines.  The facility was made aware of this finding, but requested that these sources remain permitted.  Furthermore, it was discovered that the cold cleaner degreasers (six degreasers) (ES40 (former IES24)), hot melt adhesives application (ES9 (former (IES9)), and application of label glue (ES30 (former IES30)) no longer qualify for exemption from permitting per 15A NCAC 2Q .0102(c)(2)(D)(i)  -  graphic arts operations, paint spray booths or other painting or coating operations without air pollution control devices (water wash and filters that are an integral part of the paint spray booth are not considered air pollution control devices), and solvent cleaning operations located at a facility whose facility-wide actual emissions of VOC are less than five tons per year...  -  since actual VOC emissions from said sources are expected to exceed five tons per year.  Therefore, these sources were added to the permitted emissions sources list with IDs as requested by Mr. Loftis (see attachment A).

The facility owns/operates the following emissions sources and control devices (the changes for this revision are illustrated in bold and/or strikethrough text).

                Permitted Emissions Sources and Control Devices
                              Emissions Source ID
                         Emissions Source Description
                               Control System ID
                          Control System Description
                                 ES-1 and ES-2
                                 (MACT DDDDD)
Two coal/No. 2 fuel oil/No. 6 fuel oil-fired boilers (238 million Btu per hour heat input, each)
                                     CD-1
                                     CD-2
Two electrostatic precipitators (41,760 square feet of collecting plate area, each)
                                     ES-3
                                 (MACT DDDDD)
One No. 2 fuel oil/No. 6 fuel oil-fired boiler (136 million Btu per hour heat input)
                                      N/A
                                      N/A
                                     ES-4
                        One boiler ash handling system
                                     CD-4A
One air washer (7.1 square feet of collection surface area) installed on the boiler bottom ash exhaust and the flyash exhaust from the electrostatic precipitators
                                     ES-4
                        One boiler ash handling system
                                     CD-4B
One bagfilter (84 square feet of filter area) installed on the bottom ash silo
                                       
                                       
                                     CD-4C
  One bagfilter (84 square feet of filter area) installed on the flyash silo
                                     ES-6
                                 (MACT DDDDD)
     One No. 2 fuel oil-fired boiler (5.6 million Btu per hour heat input)
                                      N/A
                                      N/A
                                     ES-15
                     One brew house cleaning vacuum system
                                   CD-15A.1
                                   CD-15B.1
One cyclone (30 inches in diameter) and one bagfilter (86 square feet of filter area)
                                       
                                       
                                   CD-15A.2
                                   CD-15B.2
One cyclone (30 inches in diameter) and one bagfilter (86 square feet of filter area)
                                     ES-24
                                 Cold services
                                      N/A
                                      N/A
                                     ES-31
                               Product packaging
                                      N/A
                                      N/A
                                     ES-32
       One quality control coding ink application on the packaging lines
                                      N/A
                                      N/A
                                     ES-36
                          Wastewater treatment plant
                                      N/A
                                      N/A
                                 ES-37 (EmGen)
                      (MACT NSPS IIII & NESHAP ZZZZ)
One new (150 kW electrical output; 270 hp engine) emergency diesel fuel fired generator
                                      N/A
                                      N/A
                                     ES-38
                              (MACT NESHAP ZZZZ)
                    One existing (170 HP) diesel fired pump
                                      N/A
                                      N/A
                                     ES-39
                      (MACT NSPS IIII & NESHAP ZZZZ)
                      One new (140 HP) diesel fired pump
                                      N/A
                                      N/A
                                     ES40
                   Cold cleaner degreasers (six degreasers)
                                      N/A
                                      N/A
                                      ES9
                        Hot melt adhesives application
                                      N/A
                                      N/A
                                     ES30
                           Application of label glue
                                      N/A
                                      N/A

                           Exempt Emissions Sources
                                   Source ID
                              Source Description
                         15A NCAC Exemption Regulation
                                     IES1
             Warehousing operations (including bottle warehousing)
2Q .0102(c)(2)(E)(i)  -  Any source whose emissions would not violate any applicable emissions standard and whose...potential uncontrolled emissions, would each be no more than five tons per year and whose potential emissions of hazardous air pollutants (HAP) would be below their lesser quantity cutoff
                                     IES2
                               Spent grain silo
                                       
                                     IES4
                          (MACT, Subpart NESHAP ZZZZ)
One diesel-fired emergency generator (12 kW electrical output; 16 18 hp engine)
2Q .0102(c)(2)(B)(v)(III)  -  Emergency use generators...that have a rated capacity of no more than...590 kW (electric) or 900 hp for diesel-fired...engines
                                 IES5 [112(r)]
                          Ammonia refrigerator system
                             2Q .0102(c)(2)(E)(i)
                                     IES6
                              CO2 recovery system
                                       
                                     IES7
                       Specialty malt handling/receiving
                                       
                                     IES8
                      Spice addition system to brewhouse
                                       
                                     IES9
                        Hot melt adhesives application
                                      N/A
                                     IES10
          One No. 6 fuel oil storage tank (1,000,000 gallon capacity)
                                      N/A
                                     IES11
           One No. 2 fuel oil storage tank (30,000 gallon capacity)
                                      N/A
                              IES12.1 and IES12.2
          Two diesel fuel storage tanks (2,500 gallon capacity each)
2Q .0102(c)(1)(D)(i)  -  Storage tanks used solely to store fuel oils, kerosene, diesel, crude oil, used motor oil, lubricants, cooling oils, natural gas or liquefied petroleum gas
                                     IES13
                                (NESHAP CCCCCC)
               One gasoline storage tank (2,500 gallon capacity)
       2Q .0102(c)(1)(D)(ii)  -  Storage tanks used to store gasoline...
                                     IES14
                                Cooling towers
                             2Q .0102(c)(2)(E)(i)
                                     IES15
                     Utilities carbon regeneration system
                                       
                                     IES16
                   One used oil tank (1,000 gallon capacity)
                             2Q .0102(c)(1)(D)(i)
                                     IES17
                                 Coal bunkers
                                      N/A
                                     IES18
One raw materials unloading and transfer system, including the unloading pit, and malt, grit, black malt, and caramel malt silos with associated bagfilters (Nos. CD-11A, and CD-11B, and CD-11C) (formerly ES11)
                             2Q .0102(c)(2)(E)(i)
                                     IES19
One grain transfer system, including Nos. 1 and 2 malt receivers, grit receiver, and malt mills with associated bagfilters (Nos. CD-12A, CD-12B, CD-12C, and CD-12D) (formerly ES12)
                                       
                                     IES20
One wastewater treatment plant lime storage silo with associated bagfilter (No. CD-21) (formerly ES21)
                             2Q .0102(c)(2)(E)(i)
                                     IES21
          General maintenance  -  welding, degreasing, grinding, etc.
2Q .0102(c)(1)(A)(i)  -  maintenance, structural changes, or repairs which do not change the capacity of such process, fuel-burning, refuse-burning, or control equipment, and do not involve any change in quality or nature or increase in quantity of emission of regulated air pollutants;
                                     IES22
Premix room, DE warehouse, Precoat and Body feed and outside the ceramic filter room controlled by multiple fabric filters for diatomaceous earth handling system
                             2Q .0102(c)(2)(E)(i)
                                     IES23
                       Brewhouse (including wort tanks)
                                       
                                     IES24
                            Cold cleaner degreasers
                                      N/A
                                     IES25
                                   Cold pile
                                       
                                     IES26
                        Diatomaceous earth premix tanks
                             2Q .0102(c)(2)(E)(i)
                                     IES27
      One Igniter Oil Storage Tank for ES1 and ES2 (8000 gallon capacity)
                             2Q .0102(c)(1)(D)(i)
                                    IES28.1
   One Diesel Fuel Storage Tank for Fire Pump IES 3.1 (550 gallon capacity)
                                       
                                    IES28.2
   One Diesel Fuel Storage Tank for Fire Pump IES 3.2 (550 gallon capacity)
                                       
                                     IES29
    One No. 2 Oil Storage Tank for WWTP Boiler ES6 (10,000 gallon capacity)
                                       
                                     IES30
                           Application of Label Glue
                                      N/A
                                    IES-36
                          Wastewater treatment plant
            2Q .0102(c)(1)(F)  -  Wastewater treatment processes...
                                     IES33
                          Diatomacious earth handling
                             2Q .0102(c)(2)(E)(i)

 REVIEW OF REGULATIONS
The facility is subject to the following Title 15A NCAC regulations, save any regulations removed from the permit for this revision.  Only regulations warranting discussion due to the facility's modifications, those deemed necessary by this permit writer, and any regulatory changes since the last revision are addressed.

2D .0202  -  Registration of Air Pollution Sources (Added)
2D .0503  -  Particulates from Fuel Burning Indirect Heat Exchangers (Removed)
2D .0515  -  Particulates from Miscellaneous Industrial Processes
2D .0516  -  Sulfur Dioxide (SO2) Emissions from Combustion Sources
2D .0521  -  Control of Visible Emissions (VE)
2D .0524  -  New Source Performance Standards (NSPS)
2D .0535  -  Excess Emissions Reporting and Malfunctions
2D .0540  -  Particulates from Fugitive Dust Emission Sources
2D .0605  -  General Recordkeeping and Reporting Requirements (Added)
2D .0614  -  Compliance Assurance Monitoring (CAM) (Removed)
2D .0958  -  Work Practices for Sources of VOC
2D .1111  -  Maximum Achievable Control Technology
2D .1806  -  Control and Prohibition of Odorous Emissions
2D .2100  -  Risk Management Program (RMP) (Added)
2Q .0315  -  SM Facilities (Added)
2Q .0500  -  TV Procedures (Removed)
2Q .0508(g)  -  Permit Content (Removed)

2D .0202  -  Registration of Air Pollution Sources
This regulation applies and allows the Director to require a facility to report, as in this case, total weights and kinds of air pollution released as well as any other information considered essential in evaluating the potential of the source to cause air pollution.  Since this revision is a modification only, the facility was not required to submit an emissions inventory (EI).  The facility is required to submit an EI for CY2014 by June 30, 2015 (per the former TV permit) and an EI for CY2014, 90 days prior to the expiration of this permit.  It seems reasonable to anticipate compliance.

2D .0503  -  Particulates from Fuel Burning Indirect Heat Exchangers
This regulation does not apply.  This rule limits particulate matter (PM) emissions that are discharged from any stack or chimney into the atmosphere from sources in which fuel is burned for the purpose of producing heat or power by indirect heat transfer.  Fuels include those such as coal, coke, lignite, peat, natural gas, and fuel oil (FO), but exclude wood and refuse not burned as a fuel.  Since the facility no longer owns/operates any indirect heat exchangers, this rule was removed from the permit for this revision.

2D .0605  -  General Recordkeeping and Reporting Requirements
This regulation applies and was added to the permit for this revision since the facility was permitted as a TV facility for CY2015 until the effective date of this permit.  The facility is required to submit a compliance certification to the DAQ and to the EPA within 45 days of the issuance date of this permit.  The compliance certification must encompass CY2015 from January 1[st] through the effective date of the permit and be certified by a responsible official with all federally-enforceable terms and conditions in the TV permit, including emissions limitations, standards or work practices as described in the TV permit in accordance with 15A NCAC 2Q .0508(m).  The compliance certification shall comply with additional requirements as may be specified under Sections 114(a)(3) or 504(b) of the Federal Clean Air Act (CAA).  The compliance certification shall specify: 1) the identification of each term or condition of the TV permit that is the basis of the certification; 2) the compliance status; 3) whether compliance was continuous or intermittent; and 4) the method(s) used for determining the compliance status of the source, currently and over the reporting period.  The facility complied with this rule when it operated as a TV facility, so it seems reasonable to anticipate continued compliance.

2D .0614  -  CAM
This regulation does not apply.  This rule previously applied to the coal/No. 2 FO/No. 6 FO-fired boilers (ES-1 and ES-2).  Since the subject sources were removed from the permit, this rule was removed from the permit for this revision.

2D .2100  -  RMP
This regulation applies and was added to the permit for this revision  -  these requirements previously appeared at the condition requiring compliance with 2Q .0508(g) in the TV permit.  The facility is subject to Section 112(r) of the CAA and the RMP requirements per 40 CFR Part 68, Subpart G.  According to the report for the latest compliance inspection, "This facility is subject to Program Level 3 of Section 112(r) of the CAA, as 100,000 pounds of anhydrous ammonia is stored onsite, more than the threshold amount of ammonia (10,000 pounds).  Ray Stewart, P.E., DAQ-WSRO Compliance Supervisor, last conducted a complete 112(r) inspection on August 15, 2012.  The facility was found to be in compliance with the requirements of Section 112(r) of the CAA during that inspection.  During this general TV inspection, the facility had a current RMP dated January 5, 2012."  Compliance is indicated and it seems reasonable to anticipate continued compliance.

2Q .0315  -  SM Facilities
The facility is subject to this regulation.  This rule allows a facility to choose to have terms and conditions placed in the permit to limit emissions and restrict operations in order to avoid TV applicability and be classified as a SM facility.  For this revision, the calculations do not show the facility has the facility-wide potential (before controls/limits) to emit over 100 tons of VOC per year (see 7.  FACILITY-WIDE EMISSIONS), but Mr. Loftis indicated "...MillerCoors would prefer the conservative approach of requesting a synthetic minor limit for VOC..." (see attachment A).  It was also determined the facility has the facility-wide potential (before controls/limits) to emit more than 100 tons of PM10 per year (see 7.  FACILITY-WIDE EMISSIONS) so PM10 was added to this condition.

The facility did not request any restrictions (i.e. process limits, operational limits, operating hours limits, etc...) appear at this condition.  Since no restrictions were requested, a more stringent condition requiring the facility to record monthly and total monthly (for the previous 12 months) facility-wide VOC emissions is included at this condition.  The facility is also required to utilize the cyclones and bagfilters and perform periodic inspections and maintenance on said control devices as recommended by the manufacturer.  Annual inspections of each cyclone, and annual internal inspections of each bagfilter, are required.  All inspection, maintenance, and monitoring requirements associated with the cyclones and bagfilters are required to be recorded in a logbook, which is required to be kept on-site and made available to DAQ personnel upon request.  These requirements for the cyclones and bagfilters appeared in the TV permit, but it is noted the requirement for monthly visual inspections of the system ductwork, bagfilters and cyclones for leaks that appeared in the TV permit is not included in this permit.

The facility is required to report facility-wide VOC emissions (monthly and 12 month totals for the previous 12-month period) within 30 days after each calendar year quarter.  Quarterly reporting is required since facility-wide projected actual VOC emissions exceed 75 tons per year (see 7.  FACILITY-WIDE EMISSIONS); however, quarterly reporting could be relaxed to annual reporting should actual facility-wide VOC emissions be less than 75 tons per year.  It seems reasonable to anticipate compliance.

2Q .0500  -  TV Procedures
This regulation does not apply.  Since the facility is no longer classified as a TV facility, all references to TV procedures, except for final requirements, were removed from the permit for this revision.

2Q .0508(g)  -  Permit Content
This regulation does not apply.  As previously mentioned, the facility is subject to Section 112(r) of the CAA and the RMP requirements per 40 CFR Part 68, Subpart G and the requirements appeared at the condition requiring compliance with 2Q .0508(g) in the TV permit.  Since the facility no longer holds a TV permit, this condition was removed from the permit and the requirements now appear at the condition requiring compliance with 2D .2100.

 NSPS / NATIONAL EMISSIONS STANDARDS FOR HAZARDOUS AIR POLLUTANTS (NESHAP) / PREVENTION OF SIGNIFICANT DETERIORATION (PSD) / 112(r) / ATTAINMENT/NON-ATTAINMENT STATUS
NSPS  -  The facility owns/operates sources subject to a NSPS rule promulgated at 40 CFR Part 60.

The engines associated with emergency generator ES-37 and fire pump ES-39 are subject to 40 CFR Part 60, Subpart IIII  -  Standards of Performance for Stationary Compression Ignition Internal Combustion Engines (CI ICE).  This rule applies to owners and operators of stationary CI ICE that commence construction (i.e., order the engines) after July 11, 2005 where the stationary CI ICE are manufactured after April 1, 2006 and are not fire pump engines, or manufactured as a certified National Fire Protection Association fire pump engine after July 1, 2006.  The application packet for revision T22 indicates emergency generator ES-37 and fire pump ES-39 were both constructed and manufactured in 2012; therefore, these sources are subject to this rule.  The applicable standards and requirements are listed in the permit (see the permit for details).  The application packet indicates the engine associated with fire pump ES-38 pre-dates applicability of this rule and the application packet for revision T19 indicates emergency generator IES4 was purchased in 1980; therefore, these engines are not subject to this rule.

The exempt storage tanks containing diesel, gasoline, FO, and used oil (550 to 10,000 gallons) are not subject to 40 CFR Part 60, Subpart Kb  -  Standards of Performance for Volatile Organic Liquid (VOL) Storage Vessels (Including Petroleum Liquid Storage Vessels) for Which Construction, Reconstruction, or Modification Commenced After July 23, 1984.  This rule does not apply to storage tanks with capacities less than 75 cubic meters (approximately 19,813 gallons) that are used to store VOL and storage vessels located at gasoline service stations (defined by the rule as "...any site where gasoline is dispensed to motor vehicle fuel tanks from stationary storage tanks...").  All the storage tanks have capacities less than 19,813 gallons and it appears the gasoline storage tank is located at a gasoline service station as defined by the rule; therefore, this rule does not apply.

None of the sources are subject to 40 CFR Part 60, Subpart QQ  -  Standards of Performance for the Graphic Arts Industry: Publication Rotogravure Printing, since the facility has no publication rotogravure printing presses.

NESHAP  -  The facility owns/operates sources subject to a NESHAP rule promulgated at 40 CFR Part 63.  The facility currently does not own operate any sources subject to rules promulgated at 40 CFR Part 61.

The engines associated with the emergency generators (ES-37 and IES4) and fire pumps (ES-38 and ES-39) are subject to 40 CFR Part 63, Subpart ZZZZ  -  NESHAP for Stationary Reciprocating Internal Combustion Engines.  This rule applies to owners and operators of RICE at major and area sources of HAP emissions.  According to the rule, a stationary RICE located at an area source of HAP emissions is new if it was constructed on or after June 12, 2006 and is existing if it was constructed or reconstructed before June 12, 2006.  As previously mentioned, emergency generator ES-37 and fire pump ES-39 were both constructed and manufactured in 2012; therefore, the engines associated with these sources are considered new.  According to the rule, "An affected source that is a new...RICE located at an area source...must meet the requirements of this part by meeting the requirements of 40 CFR part 60 Subpart IIII, for compression ignition engines...No further requirements apply for such engines under this part."  The application packet indicates emergency generator ES-38 was constructed prior to June 12, 2006 and, as previously mentioned, the application packet for revision T19 indicates emergency generator IES4 was purchased in 1980; therefore, these engines are considered existing.  The applicable requirements for all the subject engines, except for IES4, are listed in the permit (see the permit for details).  Only reference to the requirements for emergency generator IES4 is included in the permit since this source is exempt from permitting.

The exempt storage tank containing gasoline (IES13) is subject to 40 CFR Part 63, Subpart CCCCCC  -  NESHAP for Source Category: Gasoline Dispensing Facilities (GDF).  This rule applies to each GDF that is located at an area source of HAP emissions and the affected sources include each gasoline cargo tank during the delivery of product to a GDF and each storage tank.  According to additional information received, the facility's monthly gasoline throughput is less than 10,000 gallons of gasoline; therefore, the requirements at §63.11116 apply.  The facility must not allow gasoline to be handled in a manner that would result in vapor releases to the atmosphere for extended periods of time. Measures to be taken include, but are not limited to: 1) minimize gasoline spills; 2) clean up spills as expeditiously as practicable; 3) cover all open gasoline containers and all gasoline storage tank fill-pipes with a gasketed seal when not in use; and 4) minimize gasoline sent to open waste collection systems that collect and transport gasoline to reclamation and recycling devices, such as oil/water separators.  The facility is not required to submit notifications or reports as specified in §63.11125, §63.11126, or 40 CFR Part 60, Subpart A, but must have records of gasoline throughput available within 24 hours of a request.  Portable gasoline containers that meet the requirements of 40 CFR Part 59, Subpart F are considered acceptable for compliance with measure three above.  It seems reasonable to anticipate compliance.  Since the gasoline storage tank qualifies for exemption from permitting, a condition notifying the facility of its responsibility for compliance with this rule was added to the permit.

None of the sources are subject to 40 CFR Part 63, Subparts KK  -  National Emission Standards for the Printing and Publishing Industry, because this rule applies to facilities that are major for HAP emissions.  The facility is minor for HAP emissions; therefore, this rule does not apply.

PSD  -  The facility was previously major for PSD; however, since the facility was constructed prior to the 1977 promulgation date of the PSD rules, the facility was considered a "grandfathered" source and not subject to PSD review.  Due to the modifications associated with this revision, the facility is now minor for PSD since it does not have the potential to emit more than 250 tons of any criteria pollutant per year (after controls) and does not own/operate any of the 28 named PSD source categories limited to 100 tons of any criteria pollutant per year (after controls).  PM10, SO2, and NOx emissions have been triggered for PSD increment tracking in Rockingham County with a baseline date of September 25, 1998.  For this revision, PM10, NOx, and SO2 emissions are expected to decrease due to the removal of several emissions sources, but a review of the facility's source files indicated increment tracking has not been reported for the facility.  Therefore, increment tracking is not necessary.

112(r)  -  The facility is subject to this regulation (see 4.  REVIEW OF REGULATIONS, 2D .2100  -  RMP).

ATTAINMENT/NON-ATTAINMENT STATUS  -  Rockingham County is considered as in attainment or unclassifiable for all regulated criteria pollutants.

 TOXICS APPLICABILITY
The facility has never triggered toxics rules and a toxics review was not triggered for this revision.

 FACILITY-WIDE EMISSIONS
The projected actual and potential emissions (after controls/limits) are from the supporting calculations included in the application packet.  It is noted that neither the facility, nor their consultant, provided calculations/emissions estimates for PM10 emissions (before controls).  In lieu of not providing this information and for simplicity, it was assumed that all PM from the brew house cleaning vacuum system (ES-15) is equal to PM10 and the control device efficiency for the control systems are 99.9%.  Based on these assumptions, potential PM10 emissions (before controls) were estimated as follows, which seems to be a reasonable estimate.

		PM10 (before controls) = (0.41 tons/yr) / (1  -  0.999) = 410 tons/yr

The changes in actual emissions were estimated by subtracting emissions from the CY2013 EI from the projected actual emissions.  The following table indicates the facility warrants SM classification.

                                   Pollutant
                          Projected Actual Emissions
                            (after controls/limits)
                                   [tons/yr]
                              Potential Emissions
                           (before controls/limits)
                                   [tons/yr]
                              Potential Emissions
                            (after controls/limits)
                                   [tons/yr]
                          Changes in Actual Emissions
                                   [tons/yr]
                                      PM
                                     2.24
                                   410[(1)]
                                     2.24
                                    -41.56
                                     PM10
                                     2.16
                                       
                                    <100
                                     -5.37
                                     PM2.5
                                     2.15
                                       
                                     2.15
                                     -1.44
                                      SO2
                                     0.32
                                    -677.21
                                      NOx
                                     4.91
                                    -380.15
                                      CO
                                     1.06
                                     -7.93
                                      VOC
                                     86.24
                                    <100
                                     -1.74
                                   HAPTotal
                                     3.01
                                    -22.82
                                  HAPHighest
                                3.01 (methanol)
                                    -17.94
                                    CO2(e)
                                   8,607.76
                                  -87,240.31
	(1)	Assumes PM = PM10 = PM2.5

 COMPLIANCE
Mr. King last inspected the facility on April 23, 2014.  According to the report for said inspection, "Based on review of records and visual observations, this facility appeared to be operating in compliance with Air Quality standards and regulations at the time of this inspection."  Regarding violations issued to the facility in the last five years, Mr. King noted,

"April 9, 2013  -  NOV/NRE for failure to conduct a bagfilter inspection in a timely manner, inaccurate semiannual TV report, and inaccurate TV ACC. The report was due January 30, 2013, and was received on January 28, 2013. The ACC was due March 1, 2013, and received on February 28, 2013. Enforcement was not pursued, due to facility's alerting of DAQ to the issue promptly. A no-enforcement memo was filed on May 10, 2013.

March 11, 2013  -  NOV for an inaccurate semiannual TV report and inaccurate TV ACC. The report was due January 30, 2013, and was received on January 28, 2013. The ACC was due March 1, 2013, and received on February 28, 2013.

August 2, 2012  -  NOD for late semiannual TV report. The report was due on July 30, 2012, and received on August 1, 2012."

 APPLICATION FEE / ZONING CONSISTENCY DETERMINATION (ZCD)
An application fee is required for a permit modification application and a check in the amount of $400.00 was included in the application packet.  This is the correct amount since this review determined the facility's fee classification is SM, for which the permit modification application fee is currently $400.00.

A ZCD is required for a permit modification that involves expansion of a facility.  The modifications associated with this application do not involve expansion of the facility; therefore, this rule does not apply.

 RECOMMENDATION
It is recommended that permit 03116R23 be issued to MillerCoors LLC - Eden Brewery.

 SUMMARY OF ATTACHMENT
The following attachment accompanies this review.

                                  Attachment
                                  Description
                                       A
Correspondence between DAQ and facility personnel

